Grimm v. Columbus Savings Bank Co.

25 Ohio N.P. (n.s.) 203

This text of 25 Ohio N.P. (n.s.) 203 (Grimm v. Columbus Savings Bank Co.) is published on Counsel Stack Legal Research, covering Court of Common Pleas of Ohio, Franklin County, Civil Division primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Grimm v. Columbus Savings Bank Co., 25 Ohio N.P. (n.s.) 203 (Ohio Super. Ct. 1924).

Opinion

Scarlett, J.

“This ease, begun by the receiver to recover for the benefit of eheckholders and general creditors the amount of his company’s general deposit, is now before the court upon a demurrer to the answer of the defendant bank. The facts as presented by the answer are as follows; that the plaintiff was appointed receiver of the Columbus Pump Supply Company on April 25, 1922, at which time it had on deposit with the defendant bank the sum of $1,178.61, and was indebted to said bank on its note for $3,800, which was not due until June 13, 1922; that for a considerable time prior to April 25th the Supply Company was insolvent; and prior to the appointment of the receiver issued checks in the due course of business to the amount of $1,153.89, which had neither been presented to nor accepted by the bank prior to the receivership or to the applica[204]*204tion of the deposit by way of equitable setoff on the note, which the bank alleges it did on April 26th.

The sufficiency of the answer depends upon three main propositions, namely:

, (1) That a bank, if and when the maker of a note becomes insolvent, has the right to apply his deposit by way of equitable setoff toward the payment of the note, although said note is not due.

(2) That the right is not defeated pro tanto by checks issued in the due course of business to holders, who neither presented • them nor -secured their acceptance prior to the receivership or to the exercise of the right of setoff.

\ (3)-,, That if the right existed prior to the receivership, it isi-not- lost by the failure of the bank to exercise it before the appointment of the receiver.

..As; a general rule a bank may apply debtor’s deposits to-the payment of his debts to the bank as they come due. As to unmatured debts the question is a different one. The clear weight of 'authority, however, is to the effect that where a depositor becomes insolvent the bank may by way of equitable setoff apply his deposit • to the payment of an unmatured note. (7 C J. 656). •

The doctrine of equitable setoff had its origin in a very early day, and has always been applied by courts of equity in all cases of mutual demands when the dictates of natural justice rendered it appropriate; no superior rights of third- persons haying intervened before suit. (Wunderlich v. Merchants National Bank, 109 Minn., 468, 27 L. R. A. N. S., 811). “The natural equity to have mutual but unconnected demands between two parties, who have been dealing with each other, set-off' is, as a general rule, superior to the claim of any creditor who. has not dealt with the insolvent upon the faith of-the specific fund against which the right of setoff is claimed.”. (Waterman Set-Off, 617). When the debt of one mutual debtor is unmatured, his insolvency is the necessary basis of the exercise of the right by the other, as otherwise it must be assumed that he can collect the debt when it matures, while insolvency with, its assurance of loss “renders appropriate” the application of the doctrine in the interests of natural justice. The [205]*205bank, for instance, undoubtedly made tbe loan because tbe company was a depositor, and having relied more thereon than any general creditor or eheckholder, who had no special knowledge thereof, has a much stronger equitable appeal. .

In support of their contention that the right of the bona- fide eheckholder is superior to the bank’s right of equitable setoff, the plaintiff cites 7 Corpus Juris 656, where it is said “but such application can not be made as aganist a bona fide eheckholder who presents his check before the maturity of the debt.” In support of the statement, Illinois, Kentucky, Missouri and Nebraska cases are cited, as well as a lower court decision in Ohio (Shunk v. Merchants National Bank, 9 O. Dec. (Rep.) 684, 16 Cin. L. B. 353.)

An examination of these cases shows that in these other states, the bona fide eheckholder actually has a superior right because it is there held that “a check operates as an equitable, if not legal assignment of that proportion of the deposit necessary to pay it, and becomes fixed and binding upon bank upon presentation” (Fourth National Bank v. City National, 68 Ill. 398), the bank becoming thereby “the holder of the drawer’s money to the use of the holder, and bound to account to him for the amount.”

In the Missouri ease Zeele v. German Sav. Inst., 4 Mo. Appl. 401, the argument is premised upon the right of the'depositor “to sue and recover if the cheek was presented for payment and payment refused when bank was in funds” of depositor sufficient to pay check. In Kentucky the bona fide check-holder has the same right (National Bank v. Robinson, 97 Ky. 552), while in Nebraska his right is thus described (Bank v. Bank, 56 Neb. 803) : “A check upon a bank by a depositor operates as a transfer of its amount to the payee, if on deposit at time of presentation, and payee or holder upon refusal may maintain suit.” ■ ■

In Ohio the eheckholder has no such superior right, by means of which he can defeat the right of equitable setoff. Here a check or draft “does not, before acceptance by the drawee, constitute an equitable assignment of the amount for which it is drawn” (Covert v. Rhoades, 48 O. S. 66); nor “is it an as[206]*206signment pro tanto without acceptance by the. bank.” (Bank v. Brewing Co., 50 O. S. 151.

“It is simply an order which may be countermanded and payment forbidden by the drawer anytime before it is actually cashed or accepted.” (54 O. S. 72.)

Such being the character of a check in Ohio, the checkholder until acceptance has no right whatever against the bank a,nd no right of action against it for refusal to pay the cheek. (Railroad v. Bank, 54 O. S., 60.)

By statute it is declared that “the bank is not liable to the holder, unless and until it accepts or certifies the check.” (Sec. 8294 General Code; Banking Co. v. Bin Co., 92 O. S., 406.)

In Ohio,' therefore, the,, checkholder is merely a general creditor, and is entitled to no preference over other general creditors. Certainly he has no superior right, either in law or equity, capable of defeating the right of the bank to balance its account by way of equitable set-off.

In the Ohio case cited, Skunk v. Bank, 9 O. D., 684, the Superior Court upheld the bank’s right of equitable setoff against the insolvent or his general assignee, but in the syllabus by way of obiter denied the right in cases involving “bona fide holders of checks for value. Its mistake in this respect ,was due to the fact that it relied upon the opinion of the federal court of the Missouri district (Bank v. Coates, 3 McCready 9), where the checkholder has a right of action against the 'bank, as above outlined.

In Georgia, where ordinary checks “are neither assignments nor appropriations pro tanto of the fund,” it was held that the depositary bank, holding unmatured notes has the-right.-of equitable setoff upon the failure and insolvency of the other, regardless of outstanding checks. (Georgia Seed Co. v. Talmadge & Co., 96 Ga., 254, 258). The same right was maintained in Iowa as against bona fide checkholders .(35 L. R. A. 379), and in Minnesota as against garnishee proceedings. (Her

Free access — add to your briefcase to read the full text and ask questions with AI

Related

Georgia Seed Co. v. Talmadge & Co.
22 S.E. 1001 (Supreme Court of Georgia, 1895)
Brothers v. Girard National Bank
93 A. 940 (Supreme Court of Pennsylvania, 1915)
Columbia National Bank v. German National Bank
77 N.W. 346 (Nebraska Supreme Court, 1898)
Fourth National Bank v. City National Bank
68 Ill. 398 (Illinois Supreme Court, 1873)
Merchants' National Bank v. Robinson & Co.
31 S.W. 136 (Court of Appeals of Kentucky, 1895)
Wunderlich v. Merchants National Bank
124 N.W. 223 (Supreme Court of Minnesota, 1910)

Cite This Page — Counsel Stack

Bluebook (online)
25 Ohio N.P. (n.s.) 203, Counsel Stack Legal Research, https://law.counselstack.com/opinion/grimm-v-columbus-savings-bank-co-ohctcomplfrankl-1924.